FedGlobal ACH Payments Service Origination Manual - Updated June 1, 2021
←
→
Page content transcription
If your browser does not render page correctly, please read the page content below
Table of Contents Introduction .................................................................................................................................................................. 3 Purpose ......................................................................................................................................................................... 3 Document History ......................................................................................................................................................... 3 Overview ....................................................................................................................................................................... 4 General Description ....................................................................................................................................................... 4 ODFI Compliance Obligations ........................................................................................................................................ 4 RDFI Compliance-Related Inquiries ............................................................................................................................... 5 FedGlobal ACH Payments Compliance .......................................................................................................................... 6 Dodd-Frank 1073 Compliance………………………………………………………………………………………………………………………………….6 Risks ............................................................................................................................................................................... 8 Rules Differences ........................................................................................................................................................... 9 Holiday Processing....................................................................................................................................................... 10 Customer Support ....................................................................................................................................................... 10 Implementation Requirements .................................................................................................................................. 10 Service Request Form .................................................................................................................................................. 10 Pre-production Testing ................................................................................................................................................ 11 FedGlobal ACH Payments Geographic Reach ............................................................................................................ 11 Country/Region Requirements .................................................................................................................................. 12 CANADA ...................................................................................................................................................................... 12 MEXICO ....................................................................................................................................................................... 18 PANAMA ..................................................................................................................................................................... 30 EUROPE ....................................................................................................................................................................... 34 Appendix I – IAT Format Origination Matrix.............................................................................................................. 42 Appendix II – IAT Format Origination Matrix / F3X Payments .................................................................................. 51 Appendix III – Guide to a Successful FedGlobal ACH Payments Launch ................................................................... 57 Appendix IV – Mexico F3X Specifications .................................................................................................................. 58 Appendix V – Europe F3X Specifications .................................................................................................................... 59 Appendix VI – FedGlobal ACH Payments ISO Destination Country and Currency Codes……………………………………….60 Appendix VII – Instructions for Tracing Payments in Mexico’s SPEI System ............................................................ 61 Appendix VIII – FedGlobal ACH Payments Mexico Service ABM Numbers for RDFIs ............................................... 62 Appendix IX – FedGlobal ACH Payments Panama Service Bank Numbers for RDFIs................................................ 64 2
Introduction FedGlobal ACH Payments is an enhanced suite of international ACH services established to complement FedACH® Services. The portfolio of international ACH services provides a significant increase in the number of countries reachable and payment options available from FedACH. Ultimately, broader country reach, as well as flexibility with payment options allows the Federal Reserve Banks to offer an efficient means of cross-border ACH payments to all originating depository financial institutions (ODFIs). Purpose This manual is intended to assist financial institutions in establishing an international ACH origination program using the Federal Reserve Banks’ FedGlobal ACH Payments Service. The manual will provide an overview of the service, processing, and implementation requirements, as well as country and/or region- specific requirements for the purposes of originating international ACH payments. It is a living document that will be revised as service enhancements are identified and implemented. Your account executive can assist you in implementing a successful international ACH origination program. To determine the appropriate , please visit https://frbservices.org/contactus/account- executives.html. This FedGlobal ACH Service Origination Manual should be used in conjunction with Federal Reserve Bank Operating Circular (OC) 4 and the Nacha® Operating Rules. Since these rules may be updated or modified periodically, it is important to retain a current copy for reference. • The Nacha Operating Rules can be referenced for a definition of terms used in this manual. • The Federal Reserve’s Operating Circulars can be obtained by visiting https://frbservices.org/resources/rules-regulations/operating-circulars.html The content of this manual does not in any way constitute legal advice. It is important that ODFIs understand the specific risk and requirements involved in originating payments to foreign countries and should consult with risk management, compliance, and legal staff before originating such payments. Specifically, an ODFI that originates international ACH payments warrants under Additional ODFI Warranties for Outbound IAT Entries of the Nacha Rules that it is in compliance with the laws and payment system rules of the receiving country. Document History June 1, 2021: Updated to include reference of KYC Questionnaire periodic resubmission. Updated various hyperlinks to outside references. Updated Appendix I with notation to include each element of the receiver’s address in order. Updated RDFI bank number listings for Mexico and Panama. August 3, 2020: Updated to include references to Regulation E amendment. Updated to include references to additional countries from Europe service expansion, Geographic Reach, and ISO country code tables. Updated RDFI bank numbers list for Mexico and Panama. Updated to remove Mexico service references to Bansefi Beneficiary Account Registration (BAR) which is no longer supported. 3
Overview General Description FedGlobal ACH Payments supports the Federal Reserve’s mission to ensure an efficient, effective, and accessible retail payments system and offers a single processing stream to financial institutions for sending and receiving domestic and international ACH credit and debit 1 items using domestic FedACH deadlines. For payments originated in the U.S. and sent through FedGlobal ACH Payments, the Federal Reserve Bank of Atlanta serves as the U.S. Gateway Operator (GO) and works with the appropriate foreign gateway operator (FGO). It is important to remember that each country is governed by its own domestic clearing rules and practices. Some of the prominent differences between the U.S. and foreign country payments systems are highlighted in the appropriate section of the manual to assist you in planning and implementing your service offering. Cross-border payments are formatted using the Nacha Standard Entry Class (SEC) code IAT (international ACH transaction). The Company/Batch Header Record contains information specific to cross-border payments, including data related to foreign exchange, origination and destination country, and currency codes. Consequently, these entries can be included in the same file as domestic ACH transactions but must be batched separately. The IAT SEC code and fields in the Company Batch Header Record allow cross-border payments to be readily identified. For efficiency purposes, ODFIs need to limit their batches to fewer than 500 records. Detailed record layouts are provided in Appendix I and II of this manual. Nacha Operating Rules allow for transactions to be originated in three types of currency value exchange: fixed-to-variable (FV), variable-to-fixed (VF) or fixed-to-fixed (FF). The FedGlobal ACH Payments Service accommodates fixed-to-variable (FV) and/or fixed-to-fixed (FF) for outbound payments destined to foreign countries depending on the agreement with the FGO. These foreign exchange options include: • FV: USD to foreign currency. U.S. dollars are converted to a variable amount of destination currency based on a competitive foreign exchange rate provided as part of the payment flow. • FF: USD to USD. U.S. dollars are both sent and received to USD denominated accounts. This applies to countries that allow USD accounts and are permitted in FedGlobal ACH. • FF: foreign currency to foreign currency. This option, known as F3X 2, enables the ODFI to manage its own foreign exchange to participating countries. Settlement is conducted outside of the ACH network through a foreign correspondent. This option requires a separate service enrollment form with the Federal Reserve Banks to be able to participate. FedGlobal ACH Payments also offers the ability to send funds between deposit accounts in the U.S. and destination countries. ODFI Compliance Obligations Federal Reserve Operating Circular 4 applies to all FedACH transactions and contains provisions that apply specifically to all FedGlobal ACH Services. The Nacha Operating Rules apply to all FedGlobal ACH countries to the extent that the Nacha Operating Rules do not conflict with Operating Circular 4. Nacha’s Operating Rules outlines the obligations of Gateway Operators including responsibilities and warranties. 1 FedGlobal ACH Services offers debits to Canada only and does not introduce debits originated from any foreign country. 2 F3X is patented by the Federal Reserve Bank of Atlanta: U.S. Patent No. 7,580,886. 4
A GO serves as the entry point to, or exit point from, the United States for payment transactions. A FGO means a gateway operator that acts as an entry point to or exit point from a foreign country. The Nacha Operating Rules allow for flexibility through the U.S. GO/FGO agreement to allocate processing responsibilities, assign warranties and liabilities, establish an accord for the handling of foreign exchange, define settlement procedures, and determine the legal basis for their business relationship. Additionally, U.S. ODFIs are responsible for complying with applicable U.S. law as well as incorporating FedGlobal ACH services into applicable compliance policies and procedures. It is recommended that U.S. ODFIs have the following: a) Have a compliance officer and a compliance program that includes policies and procedures designed to ensure the USODFI’s compliance with the Bank Secrecy Act, and with U.S. laws, regulations, and bank supervisory policies regarding anti money laundering, anti terrorism financing, know your customer, customer identification programs, data security and data privacy, OFAC requirements, and mandatory consumer protections; b) Adopt and adhere to policies and procedures that ensure that all Cross-border transactions are handled in compliance with the USODFI’s compliance policies and procedures, with due regard for the enhanced OFAC requirements for international ACH transactions; c) Perform due diligence with respect to all persons, entities and associated data in every Cross-border transaction to ensure compliance with OFAC regulations, and directly involve the USODFI’s compliance staff in resolving any issues regarding any Cross-border Item that appears as if it may be a prohibited transaction under OFAC regulations; d) Monitor all Cross-border transactions for indications of suspicious activity, including but not limited to structuring such transactions to avoid recordkeeping or reporting requirements or USGO’s limits on transaction amounts; e) File Suspicious Activity Reports and/or Currency Transaction Reports as required by applicable laws or regulations. Information on OFAC regulations can be found at the OFAC web site: http://www.treas.gov/ofac/ and the Nacha Operating Rules. It is important to note that either the GO or the FGO may refuse to handle IAT items originated by any participating U.S. ODFI that they believe to pose a compliance risk, such as originating items that include parties on the OFAC list. The quality and accuracy of the information provided by the originator are key to both the ODFI and RDFI’s ability to successfully meet compliance obligations. RDFI Compliance-Related Inquiries Financial institutions that receive IAT items that entered the U.S. through FedGlobal ACH may from time to time require additional information about the payment originator. To determine if the IAT item entered the U.S through FedGlobal ACH, the RDFI can cross-reference the ODFI routing number in the E- Payments Routing Directory to verify if the Originating Gateway Operator is part of FedGlobal ACH Payments. By calling the contact number listed, the RDFI will reach FedACH and Check Services Customer Support. The RDFI should state that it is requesting assistance with a compliance-related issue. FedACH will coordinate these inquiries with the Originating Gateway Operating and will make reasonable efforts to facilitate initial communication between the depository financial institutions on both ends of the IAT item. 5
FedGlobal ACH Payments Compliance While cross-border ACH is inherently riskier than ACH payments made between counterparties within the United States, U.S. laws and regulations provide guidance to ODFIs on carrying out cross-border payments in a compliant manner. As an originator of IAT items outside the United States on behalf of U.S. ODFIs, FedGlobal ACH Payments seeks to support regulatory compliance by carrying out a series of compliance-related activities. The Federal Reserve Bank of Atlanta, the U.S. Gateway Operator for FedGlobal ACH Payments, maintains a compliance officer and compliance program aimed at ensuring that payments transacted over the FedGlobal ACH service are compliant with U.S. laws and regulations. The objective of the compliance program is to: 1) detect attempts to abuse the Federal Reserve Banks’ FedGlobal ACH services for money laundering; 2) prevent such abuse; and 3) report the attempted abuse to the requisite authorities. The Federal Reserve Bank of Atlanta’s compliance program includes: 1) transaction monitoring for Anti Money Laundering and OFAC compliance at the aggregate level; 2) transaction monitoring for limits on the payment value by originator, where applicable; 3) establishing compliance obligations for payment processing in agreements with gateway operators and third-party service providers; and, 4) due diligence reviews of service offerings that include evaluations of gateway operators and third-party service providers as well as country risk assessments. Transaction monitoring for Anti-Money Laundering may include post processing reviews of payments by ODFI, RDFI, originator, country of destination and origin, concentrations of payment activity and unusual patterns of activity. U.S. regulatory authorities will be notified of potentially suspicious payment activity. OFAC monitoring is conducted on items entering the U.S. ACH network through FedGlobal ACH Payments as requested by OFAC and the RDFI and OFAC are notified of potentially suspicious items. The transaction monitoring is conducted on a post transaction basis because FedACH as an ACH operator cannot separate out or pend suspicious items on a flow-through basis. As a gateway operator, the Federal Reserve Bank of Atlanta includes in each FedGlobal ACH Payments agreement with processors and Foreign Gateway Operators requirements that processors and Foreign Gateway Operators: 1) have a compliance officer; 2) establish and follow compliance policies and procedures; 3) be FATF compliant; 4) follow applicable record keeping requirements per local laws; and 5) follow applicable reporting requirements on illegal or suspicious transactions/activities per local laws. Due diligence activities also include a risk assessment of the foreign gateway partners and any third-party service providers involved in carrying out the service, a country risk assessment of the countries which receive, or which may originate payments into FedGlobal ACH Payments. The counter-party risk assessment evaluates operational risks, service level risks, and overall compliance risk. The country risk assessment evaluates risks presented the country or countries reached. Identified risks have been documented and mitigation procedures have been put in place. As examples, risk mitigation measures would include transaction monitoring and stipulations in legal agreements, etc. The service offerings provided by FedGlobal ACH Payments have successfully met the criteria established by the Federal Reserve Bank of Atlanta’s compliance program. Dodd-Frank 1073 Compliance In 2013, the Consumer Financial Protection Bureau (CFPB) implemented Section 1073 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank 1073). The rule, which amends Regulation 6
E, focuses primarily on disclosure, error resolution, and cancelation requirements for remittance transfer providers facilitating outbound cross-border consumer initiated electronic transfers of funds. Dodd-Frank 1073 establishes requirements for exact disclosures in most cases. However, estimated disclosures are allowed under certain circumstances. Effective July 21, 2020, the CFPB amended Regulation E pertaining to certain protections for consumers sending U.S. outbound international money transfers or remittance transfers (“Remittance Rule”). The Regulation E amended provisions on U.S. outbound cross-border transactions only pertain to consumer remittances and have no impact on non-consumer payments (i.e., business, corporate, government). The FedGlobal ACH Payments can still be used for these transactions. The following highlights the amended provisions. • Increase in safe harbor threshold from 100 to 500 transfers annually • New, permanent exception that permits insured institutions to estimate the exchange rate for a remittance transfer to a particular country if, among other things, the designated recipient will receive funds in the country’s local currency and the insured institution made 1,000 or fewer remittance transfers in the prior calendar year to that country when the designated recipients received funds in the country’s local currency • New, permanent exception will permit insured institutions to estimate covered third-party fees for a remittance transfer to a designated recipient’s institution if, among other things, the insured institution made 500 or fewer remittance transfers to that designated recipient’s institution in the prior calendar year The Regulation E amended provisions may have potential impacts for certain FedGlobal ACH Payments subscribers. The most prevalent of these pertains to responsibilities of institutions to provide exact foreign exchange (FX) disclosures. Although FedGlobal ACH Payments does not support exact FX disclosure for consumer remittances requiring US dollar to local currency conversion, institutions should consult with their legal, compliance, or supervisory authority to assess the impact of the amended provisions and when FedGlobal ACH Payments can be used. In consideration of guidelines in the final rule for the safe harbor threshold and number of remittances transferred in the prior year, the following FedGlobal ACH Payments - FX Disclosure Matrix for Consumer Remittances has been provided to assist subscribers with assessing when FedGlobal ACH Payments can be used for consumer remittances. 7
With FedGlobal ACH Payments, financial institutions are enabled with information around foreign fees, foreign taxes, and the date of funds availability, as well as estimated foreign exchange rates. Additionally, the service bolsters error resolution by assisting with the tracing of transactions where an error has occurred. Customers should consult their legal/compliance department to determine whether their institution is able to use estimates and how the information provided by the FedGlobal ACH Payments service can help satisfy disclosure obligations. FedGlobal ACH Payments offers further assistance through the FedGlobal ACH Formatting Aid, which is complimentary and available to all FedGlobal ACH Payments customers. The tool is based in Microsoft Excel® and can help financial institutions manage customer disclosures for cross-border remittances. Customers can also employ the Aid in back-office formatting of international transactions. Interested FedGlobal ACH Payments customers can obtain a copy of the formatting aid by contacting FedACH and Check Services Customer Support. The Federal Reserve Banks have evaluated how FedGlobal ACH Payments service offerings can assist customers in complying with the rule’s requirements. All attempts are made to ensure that the information provided by the FedGlobal ACH Payments service related to the payments process is accurate; however, due to differences in foreign payment system rules and practices, this information is provided on a best efforts basis and is not guaranteed. Risks Federal Reserve Operating Circular 4 and the Nacha Operating Rules stipulate the rights, obligation, and warranties with respect to the U.S. payments system. Differences in the U.S. and foreign country payments systems may pose operational risk to an ODFI. Credit risk also exists with respect to return items, including but not limited to the following example: • Return timeframes may be extended due to differences in country regulations, causing the originator to absorb extended temporal foreign exchange (FX) currency exposure and extended temporal credit risk of unsuccessful return charge back. Originators should also note that a 8
different FX rate can be applied to the originated item and the return. This difference varies by the destination currency and country. • Financial institution accounts are denominated in a particular currency. It is the responsibility of the ODFI and originator to determine the currency that the receiver’s account is denominated in and to properly format the IAT fields. Otherwise, there is the potential that if the receiving depository financial institution receives a cross-border ACH item denominated in the incorrect currency, the receiving depository financial institution may convert the item into the appropriate currency and post the item to the receiver’s account, instead of returning the item back to the foreign gateway operator. This is generally the case if there is a standing agreement between the receiving financial institution and its customer to provide the foreign exchange conversion. However, this not a requirement in some destination countries. This foreign exchange conversion is outside the scope of the FedGlobal ACH Payments service. If the receiving depository financial institution does return the item, the foreign exchange rate used does fall under the FedGlobal ACH Payments service. Ultimately, it is important for the ODFI to work with the originator to determine the appropriate destination currency related to the receiver’s account. Rules Differences As noted earlier, the Federal Reserve Banks and the appropriate FGO serve as conduits to their domestic payment systems to process and deliver international ACH payments. ACH items originated in the United States are governed by U.S. laws and rules (including the Nacha Rules), until they cross the border into another countries. Once they arrive in the foreign country, foreign country local laws and rules apply. Examples of rule differences include but may not be limited to the following: • Different return time frames by country. • Debit authorization requirements for Canada. • Ability to hold local (destination) currency and/or U.S. dollar currency accounts. • Regulatory requirements in foreign countries vary. The IAT format enables all participating U.S. financial institutions to provide the necessary and regulatory compliant information in the appropriate fields to be delivered to receiving financial institutions in foreign countries. If the information provided in the IAT fields is inaccurate or non-specific, the foreign gateway operator and/or the receiving financial institution may find it necessary to return the item. Therefore, it is important for the originating financial institution to work with the originator to be able to accurately format as well as provide quality information in the IAT records. Prenotifications and Notifications of Change (NOC) Prenotes are only supported to Panama. NOCs are only supported to Canada and Panama. To verify account information for a new receiver, a forward IAT credit for $2.00 may be sent. If the information for the receiver is incorrect, the receiving financial institution may return the item within the appropriate time frame for the receiving country. ODFI Recalls and Reversals Reversals are not supported in FedGlobal ACH Payments. If an error is detected after a file has been submitted, the U.S. ODFI should contact the originator, which in turn should work with the receiver to request a refund of the duplicated funds. In addition, the U.S. ODFI can contact FedACH, who can provide contact information for the foreign RDFI. Please refer to the Customer Support section for FedACH and Check Services Customer Support contact information. 9
The U.S. ODFI and/or originator are responsible for contacting the foreign RDFI or the beneficiary to request a refund of the item. Holiday Processing Foreign country banking holidays are not identical to U.S. banking holidays. ODFIs occasionally transmit items through FedACH for settlement on a foreign country banking holiday. When this occurs, FedACH will process the items, send to the FGO, and settle against the ODFI’s settlement account on the specified settlement date. The FGO will process, deliver, and settle the items to the foreign receiving financial institutions on the next banking day after the holiday. For payments that require a foreign exchange rate conversion, the foreign exchange rate applied will be the date of the foreign settlement date, which may be different than the U.S. settlement date. For a list of the foreign country’s holidays, please refer to the following URL for a list of bank holidays throughout the world: http://www.bank-holidays.com/index.htm Supplementary holiday schedules for FedGlobal ACH Payments participating countries may be found in the appropriate section of the manual. Customer Support ODFI Item Trace To initiate an item trace on a FedGlobal ACH Payments transaction, U.S. ODFIs should contact FedACH and Check Services Customer Support. The Federal Reserve Banks will work with the appropriate FGO to answer inquiries and a response should be provided within 3 business days. Transactions in amounts less than $20.00 may not be traced beyond FedACH (the U.S. GO) for FedGlobal ACH Payments. It is important to note that U.S. ODFIs are responsible for any investigation fees should they be assessed by foreign RDFIs or downstream payment participants. FedACH and Check Services Customer Support Toll Free 1-(877) 372-2457 Implementation Requirements Service Request Form FedGlobal ACH Payments is available to ACH originating depository financial institutions upon request. Prior to participation, a financial institution will need to complete and return the Service Request Form(s) to their Account executive. The Request Form(s) for FedGlobal ACH Payments country destinations and the F3X service are available in Part 6A and Part 6A Section B, respectively, of the FedACH Participation Agreement located at https://frbservices.org/forms/ach/index.html#fedachagreement. For questions regarding the Service Request Form(s), financial institutions should contact their Account executive. 10
Pre-production Testing To ensure that payments flow properly, an ODFI must complete testing with FedACH. To begin the testing process, financial institutions should complete the Service Request Form and submit it to their account executive. Once the completed form has been received, a FedACH testing coordinator will contact the financial institution to schedule testing. The test involves the ODFI creating an ACH file that contains a mixture of valid and invalid forward items. FedACH testing is open anytime between Tuesday and Friday. The purpose of testing is to verify the ODFI’s ability to successfully originate payments to be processed and delivered through the service using the IAT SEC code. Following a prepared test script, the ODFI submits several valid and invalid 1 and 2-day items using the standard entry class code IAT. After FedACH processes the items, FedACH will create and send the ODFI a file containing returns, which the ODFI can receive and process. Upon the completion of a successful test, participants establish a date to begin sending payments to the appropriate country. Please note that pre- production test files are not delivered to destination countries for further validation. Know Your Customer Questionnaire As a condition of using the FedGlobal ACH Payments service, participants are required to complete a Know Your Customer (KYC) Questionnaire prior to production. The KYC Questionnaire will be forwarded to the institution for completion during the due diligence and setup process. The institution’s Anti-Money Laundering (AML) Compliance Officer or another appropriate official will need to respond to the KYC Questionnaire and include their contact information. The completed KYC Questionnaire must be signed by an officer listed on the institution’s Official Authorization List (OAL) that is on file with the Federal Reserve Banks. On a periodic basis and as directed, the KYC Questionnaire must be resubmitted to remain enrolled in the service. FedGlobal ACH Payments Geographic Reach *Funds availability based on 1-Day item origination. Refer to each country/region’s section for actual cut off and delivery timeframes. 11
Country/Region Requirements CANADA Processing Service Description The Federal Reserve Bank and Scotiabank act as the gateway operators and serve as conduits to their domestic payments systems to accomplish straight-through processing of payments. The Canada Service supports both forward ACH 1-day and 2-day debits and credits originated in the U.S. and destined to any receiver’s account in Canada. As Canada is a dual-currency country, it is common practice for customers in Canada to have bank accounts denominated in either Canadian or U.S. dollars. Therefore, the Canada service allows for the flexibility in foreign exchange options, depending upon what the Canadian receiver’s account is denominated in – fixed-to-fixed (FF) or fixed-to-variable (FV). The items can be paid in a variable amount of Canadian dollars (FV-USD to Canadian dollars) based upon a daily exchange rate applied by Scotiabank or in U.S. dollars (FF- USD to USD). All settlement with U.S. participants is in U.S. dollars. For FV payments, the exchange rate is applied on the date the items are processed by Scotiabank. Scotiabank establishes the foreign exchange rate on a daily basis and is posted on the FedGlobal ACH Payments foreign exchange rate website no later than 12:00 ET each day. Daily and historic foreign exchange rate information is currently available at https://frbservices.org/app/fedachfx/home.html. Canadian Payments System Overview In Canada, the clearing and settlement of ACH payments is handled separately. There is no ACH Operator, and ACH payments are exchanged directly among banks that are known as direct clearers in the Automated Clearing Settlement System (ACSS). The Bank of Canada, which is the central bank, provides the settlement for payments processed. Canadian banks are classified as either a direct or indirect clearing bank. There are a small number of financial institutions that act as direct clearers; all other financial institutions are indirect clearers and must arrange for a direct clearer to act as an agent on their behalf within the clearing system. Direct clearers and the Canadian government exchange ACH transactions via data transmission. Settlement for these direct sends is done at the end of the day through the ACSS operated by Payments Canada, which is linked to the Bank of Canada. Each bank’s account at the Bank of Canada is adjusted based upon the net settlement data submitted. As noted earlier, ACH items originated in the U.S. are governed by U.S. laws and rules (including OC4 and the Nacha Rules) until they cross the border into Canada. Once they arrive in Canada, Canadian laws and Payments Canada rules apply. Payments Canada, as the rulemaking authority in Canada, imposes significant financial penalties for rule violations. The Canadian payment rules can be obtained from the web site at https://www.payments.ca/. In the case that Scotiabank is notified for a Payments Canada Rules violation, it will inform the ODFI that a violation has occurred and on a best effort basis, will work with the ODFI to ensure that the ODFI’s payments are compliant with Payments Canada rules. Examples of rule differences include but may not be limited to the following: 12
• Return times are longer in Canada than in the U.S. In Canada, consumers can return debits up to 90 days after the debit date. Businesses can return debits up to 10 days. Although credits are seldom returned, the same return timeframes apply. Participants in the Canada Service will need to ensure their ACH software allows for these differences in return times. • While debits into Canada are supported, originating financial institutions must be aware of, and comply with, the substantive requirements of the Canadian payment system rule H-1 on pre- authorized debits (“PAD”). Please refer directly to the CPA Rules to review the requirements of Rule H-1 at: https://www.payments.ca/resources/payment-guides/financial-institution- guides/pre-authorized-debits. • Scotiabank reviews all payments for proper compliance, including the quality of the data that is being passed from the U.S. to Canada. If for some reason, there are pertinent fields such as the receiver information, that is not properly formatted according to the Nacha formats and/or the quality of the data within the fields is not reasonable, Scotiabank will return the item back to the originating depository financial institution. Payment and Settlement Flows This section describes both processing and delivery schedules for the Canada Service. ODFIs submit a Nacha formatted file that may contain both domestic and cross-border transactions to FedACH. Cross- border items need to be batched separately within a file. FV payments also must be batched separately by debit and credit payments due to differing foreign exchange calculations for debits and credits. FedACH edits the file and validates that receipt is from an eligible participant. The deposit deadline for cross-border items is 02:15 ET. Scotiabank translates the Nacha formatted items into the Canadian format and converts the U.S. dollar amounts into Canadian dollars if the items are FV. Subsequently, Scotiabank posts the transactions to receiving accounts held at Scotiabank or distributes the transaction to RDFIs in Canada. Settlement for cross-border transactions between ODFIs and FedACH occurs in U.S. dollars and is reflected on the ACH End-of-Day Advice and Reserve Account Statement as domestic items are today. The Canadian receiver’s account is credited or debited for the full amount of the transaction; the service structure requires that no fees be deducted by the receiving institution from the principle amount of the transaction entry. Fixed-to-Variable (FV – USD to Canadian dollars) Items This section describes the FV exchange option for both debit and credit transactions. The ODFI or Sending Point (SP) deposits an ACH input file with FedACH, which receives and processes the file. The deposit deadline is 02:15 ET on FedACH processing Day 0 3. FedACH acknowledges receipt of the file for the ODFI/SP, creates the accounting entries, and makes available settlement information to the ODFI and Scotiabank. Scotiabank receives the Canadian items in the file from FedACH on Day 1. Scotiabank reformats the items, converts the U.S. dollar amounts into Canadian dollars and exchanges the payments with the Canadian banks. All settlement with U.S. participants is in U.S. dollars. 3 The convention of “Day 0” and “Day 1” is used to distinguish the “day” in which processing occurs versus the “day” in which settlement takes place and reflects the FedACH processing day cycle (e.g. start of Day “0” at 03:00 ET Monday through close of Day “0” at 02:15 ET on Tuesday). 13
Fixed-to-Fixed (FF – USD to USD) Items This section describes an ODFI sending payments to Canadian receivers using the FF payment option. The items are deposited by the ODFI/SP, received, and processed by FedACH and forwarded to Scotiabank where the items are converted into the Canadian format. In this case, there is no foreign exchange, and the items are delivered to the Canadian banks in U.S. dollars. Due to the time frames for exchanging U.S. dollars in Canada, 1-day FF payments received by FedACH after 14:45 ET will be processed as 2-day payments. “Morning Post” Delivery In an effort to have funds availability at opening of business for time critical payroll or pension payments, FedGlobal ACH Payments also offers an enhanced payment process known as “Morning Post”. The Morning Post brings uniformity to beneficiary posting that is not otherwise available for a 2-day item. Both FV and FF items meeting the three criteria below will be processed according to the Morning Post. 1. 2-day Item received by FedACH by the 14:45 ET file input deadline. 2. Nacha IAT Batch Header Record Field 13, “Effective Entry Date,” set to Day 0+2. 3. Nacha IAT First Addenda Record Field 3, “Transaction Type Code,” designated as SAL (salary) or PEN (pension). Items meeting these criteria will be delivered to Canadian RDFIs on Day 1 with funds availability to beneficiaries at the opening of business on Day 2. FedGlobal ACH Payments Canada Service Processing and Delivery Schedule FX Indicator Settlement ODFI Input Deadline FX Rate Payments & Type Date Set Delivered to RDFIs FV - CAD Day 1 02:15 ET, Day 0 10:00 ET, Day 1 14:30 ET Day 1 FF - USD Day 1 14:45 ET, Day 0 10:00 ET Day 1 FF - USD Day 1 After 10:00 ET 14:45 ET, Day 0 Day 2 to 02:15 ET, Day 0 FF - USD Day 2 02:15 ET, Day 0 10:00 ET Day 2 FV - CAD Day 2 02:15 ET, Day 0 10:00 ET, Day 2 14:30 ET Day 2 Morning Post Processing and Delivery Schedule FX Indicator & Settlement Date ODFI Input FX Rate Payments Type Deadline Set Delivered to RDFIs FF - USD Day 2 14:45 ET, Day 0 10:00 ET Day 1 FV - CAD Day 2 14:45 ET, Day 0 *10:00 ET, Day 1 14:30 ET Day 1 *Note that for the Morning Post delivery, the foreign exchange rate used for 2-day items will be the FX rate set on D+1 Holiday Schedule Canadian banking holidays are not all identical to U.S. banking holidays, and ODFIs occasionally transmit items through FedACH for settlement on a Canadian holiday. When an ODFI submits items for settlement on a national Canadian holiday that is not a U.S. holiday, FedACH will process the items and settle against the ODFI’s settlement account on the specified settlement date, and Scotiabank will process, deliver and settle the items to the receivers in Canada on the next Canadian banking day after the holiday. The FX 14
Rate will then be set according to the rate posted on the business day following the holiday and funds availability will be at the opening of business on the following day. Canadian Banking Holidays New Year's Day Family Day Good Friday Victoria Day Canada Day Civic Holiday Labor Day Thanksgiving Day Remembrance Day Christmas Day Boxing Day Notification of Change (NOCs) NOC processing is supported in the Canada Service and NOCs may be initiated to notify ODFIs in the U.S. that previously valid information contained in a posted entry has become outdated and should be changed. Scotiabank complies with the NOC format specifications outlined in the Nacha Rules. Exception Processing Return Items When Scotiabank receives files from FedACH, they are processed and posted to receiving accounts at Scotiabank or distributed to receiving institutions through the Canadian clearing system. Subsequently, Scotiabank or the Canadian RDFI may find it necessary to return an item. The item will be returned with the original dollar amount adjusted as necessary based upon the prevailing exchange rate, and the original forward item amount will be referenced in the return addenda record (field eight, position 47- 56). The procedures noted below outline the steps involved in two return item scenarios: items returned/rejected by Scotiabank and items returned by a Canadian RDFI. The items will be returned using one of the following U.S. Nacha Return Reason codes. Code Reason R01 Insufficient Funds R02 Account Closed R03 No Account/Unable to Locate Account R04 Invalid Account Number Structure R06 Returned per ODFI’s Request R07 Authorization Revoked by Customer R08 Payment Stopped R09 Uncollected Funds R10 Customer Advises Not Authorized R12 Account Sold to Another DFI R14 Representative Payee Deceased or Unable to Continue in that Capacity 15
R15 Beneficiary or Account Holder (Other Than Representative Payee) Deceased R16 Account Frozen R17 File Record Edit Criteria R20 Non-Transaction Account R24 Duplicate Entry R80 IAT Entry Coding Error R81 Non-Participant in IAT Program R82 Invalid Foreign Receiving DFI Identification R84 Entry Not Processed by Gateway Items returned by Scotiabank Upon receipt of items from FedACH, Scotiabank may be unable to process some payments and will return these payments. Items may be returned because the Canadian RTN and account numbers within the addenda records are not within Scotiabank’s defined edit range. It is critical that ODFIs ensure that items returned for edit failures are corrected before they are retransmitted. This will avoid having items reject “multiple times” for the same edit error. Additionally, Scotiabank will reject debit payments if the effective entry date is more than 173 calendar days prior to the processing date. Credit payments will be rejected if the effective entry date is more than 30 calendar days prior to the processing date. These date ranges were set by Scotiabank to conform to the timeframes established in the Payments Canada Rules. Please note that edits at Scotiabank occur after foreign exchange is applied to Fixed to Variable items. Therefore, there will not be any immediate rejects from Canada. All rejects and returns to U.S. financial institutions from Scotiabank will be converted back to U.S. Dollars on the next business day and the amount sent back will likely be less than the amount first originated. Items returned by the RDFI or receiver Items processed by Scotiabank to the receiving institution may be returned if the RDFI is unable to post the items (account closed, invalid account number, etc.). Items will generally be returned no later than the business day following receipt by the first organizational unit that is able to make or act upon a decision to accept an item. ODFI Item Trace Transactions in amounts less than $20.00 will not be traced beyond FedACH (the U.S. GO) for FedGlobal ACH Canada Service Payments. Refer to the Customer Support section for FedACH contact information to initiate an item trace request. Other Information Sample Canadian Check During the sign-up process the financial institution should work with its originator(s) and their customers to obtain accurate information on the Canadian institution’s routing and receiver’s account number(s). It is important to validate account numbers in the set-up process to ensure payment processing is not delayed once service begins. An example of a voided Canadian check is provided below. The illustration should help with identifying the Canadian routing and account numbers. 16
The check sample illustrates how to identify the “Foreign Receiving DFI Identification” number that must be inserted in field 5 of the Nacha addenda record. In the example below, padded with a leading zero, the routing transit number would be “000295042”. The receiver’s account number is “06940234567”. It is necessary to follow the routing transit formatting routine described when items are entered into the IAT format to avoid an edit failure and return of items by Scotiabank. Average Company Ltd. N408911 555 Main Street East Toronto, Ontario M5K1X1 _____________________20_______ Pay to the order of ________________________________________________________________$_______________________ VOID ________________________________________________________________________________________/100 DOLLARS The Scotiabank Bank Toronto Centre Branch 55 King St. W. & Bay St. Toronto, Ontario M5K 1A2 408911: 95042: 002: 0694:0234567 Step One: insert the receiver’s account number, ‘06940234567’ in field 8 of the IAT entry detail record. Step Two: add a leading zero to the Institution Number to = 0002 Step Three: combine with Branch Transit number to = 000295042 The routing transit number is inserted into the 5th IAT addenda record in field 5, Foreign Receiving DFI Identification. Payments Canada Member Directory Financial institutions can contact Payments Canada obtain Participant Financial Institution directories with information to help facilitate the routing of payments to the appropriate branches of Payments Canada members. https://www.payments.ca/our-directories/member-financial-institutions 17
MEXICO Processing Service Description The Federal Reserve Bank of Atlanta and Banco de México, known as Banxico, act as the gateway operators and serve as conduits to their domestic payments systems to accomplish straight-through processing of payments. The Mexico service supports both forward ACH 1-day and 2-day credits originated in the U.S. and destined to any receiver’s account. Both payment options to Mexico offer funds availability to the receiver on the U.S. settlement day. Mexican Payments System Overview Sistema de Pagos Electrónicos Interbancarios, known as SPEI, is the real-time gross settlement system owned and operated by the Central Bank of Mexico, Banco de México (Banxico). Payments processed through SPEI are settled in the accounts of Banxico. The Banco de México Act of 1993 lays down the responsibilities and powers of the Central Bank. Under this Act, Banco de México shall promote the financial system's sound development and the proper functioning of the payments system, being empowered to regulate financial operations and payment systems, including funds transfer systems operated by banks or other firms. ACH items originated in the United States are governed by U.S. laws and rules (including the Nacha Rules), until they cross the border into another countries. Once they arrive in Mexico, Mexican laws, and the rules of SPEI apply. Examples of rule differences include but may not be limited to the following: • Prenotes and NOCs are not supported in Mexico. • Return times for Mexico are shorter than in the U.S for credit items. In SPEI, timeframes for returns are the same business day as the day of receipt. If these transactions are not received within the same business day, they will need to be handled individually and outside of the SPEI network. • Mexican financial institutions do not distinguish between checking and savings accounts. In Mexico, banking institutions are identified by a three-digit number assigned by the Asociación de Banqueros de México (ABM) which is the Mexican Bankers Association. ABM has a website: http://www.abm.org.mx, but a bank number catalogue is not published. Noted in Appendix VIII is a list of the financial institutions that can be reached through FedGlobal ACH Payments. Mexican Receiver Account Numbers There are two types of account numbers that ODFIs can use to originate a cross-border item to Mexico: checking account number, known as the CLABE, or a debit card account number. 1. The CLABE (Clave Bancaria Estandarizda) is a standardized bank code that was established by the Mexican banking system for checking account numbers. It is an 18-digit number that uniquely identifies account holders and guarantees the correct posting of the electronic funds transfer operations throughout the SPEI processing platform. The CLABE replaced the previous numbering scheme for checking accounts, which was an 11-digit number. The receiver can easily identify his or her CLABE as it appears on the customer’s checking account statement or it can also be obtained directly from the bank in Mexico that offers the account. 18
An originator must ensure that it receives the 18-digit CLABE associated with the checking accounts held by receivers in Mexico to ensure that the payments can be processed. Items containing the previous 11- digit checking account number can no longer be processed successfully. 2. The second numbering scheme pertains to debit card accounts. Debit card account numbers have 16-digit numeric positions. They are not affected by the CLABE requirement, which applies only to checking accounts. Please note that debit card account numbers change if the card is lost or cancelled. All debit card accounts have a CLABE account number associated with it; therefore, it is recommended that the ODFI ask for the CLABE account number. . Calculating a CLABE Check Digit A CLABE check digit calculator is available at https://www.frbservices.org/resources/financial-services/ach/fedglobal-processing.html BBB PPP CCCCCCCCCCC D 1. ABM Bank 2. Locality 3. Account number 4. Check digit number CLABE structure 1. BBB ABM Bank Number; 3 digits. 2. PPP Locality; 3 digits. 3. CCCCCCCCCCC Checking Account number; 11 digits. 4. D Check digit, 1 digit. Calculating the check digit: Example As an example, take the CLABE where the first 17 positions are: 10315012415234578. In this case we have: 1. The check digit process involves a weight factor (3 7 1 3 7 1 3 7 1 3 7 etc.). Multiply each of the first 17 digits of the CLABE by its corresponding weight. Record only the digit in the “ones” position. For example, in the 5th position, there is a 5 * 7 = 35. Only record the “5”. 2. Sum the results of step 1. (3+0+3+3+5+0+3+4+4+3+5+2+9+8+5+1+6 = 64) 3. Take the last digit of the sum, which in this example is 4. 4. Subtract the figure from Step 3 from the number 10. (10-4 = 6; the check digit of the CLABE is 6.) Please note: If the last digit of the sum from Step 3 is 0, the check digit of the CLABE will be 0 as 10-0 is equal to 0. Position 1 2 3 4 5 6 7 8 9 1 1 1 1 1 1 1 1 0 1 2 3 4 5 6 7 A 17 Digits 1 0 3 1 5 0 1 2 4 1 5 2 3 4 5 7 8 B Weight 3 7 1 3 7 1 3 7 1 3 7 1 3 7 1 3 7 Ai*Bi Product 3 0 3 3 5 0 3 4 4 3 5 2 9 8 5 1 6 Addition result 64 PR Preliminary result 4 10-PR Check Digit 6 19
Foreign Exchange Options As the majority of accounts in Mexico are denominated in Mexican pesos, the Mexico service supports payments to be received in accounts denominated only in pesos. There are a small percentage of bank accounts denominated in U.S. dollars or other foreign currency and currently not supported in this service. Therefore, the Mexico service allows for the ability to send cross-border items using the fixed-to- variable (FV – USD to pesos), known as Directo a Mexico®, or fixed-to-fixed (FF – pesos to pesos), known as the F3X service. For the FV process, the items are originated in a fixed amount of USD and paid in a variable amount of Mexican pesos based upon a daily exchange rate applied by Banxico. The exchange rate applied is on the date the items are processed by Banxico. Banxico established the foreign exchange rate on a daily basis and is posted on the FedGlobal ACH Payments foreign exchange rate website shortly after 13:00 ET each day. Daily and historical foreign exchange rate information is available at http://www.frbservices.org/app/fedachfx/. All settlement with U.S. participants is in U.S. dollars for the FV process. For the F3X process, the items are originated and received in a fixed amount of pesos, enabling the ODFI to manage its own foreign exchange rate with its customers. Settlement is conducted outside of the ACH network through a foreign correspondent, known as the Mexican Correspondent Financial Institution (MCFI). This foreign exchange option requires a separate service request form with the Federal Reserve Banks to be able to participate. Please contact your Account executive for this service request form. Additionally, the ODFI must enter into and maintain an account with a MCFI that is authorized to participate in SPEI, and that is capable of originating and receiving payments through the SPEI system. SPEI is the Mexican real time settlement system owned and operated by Banxico. A list of MCFIs is included in the following section, Mexican Payment System Overview. There are two processing streams involved for the F3X Service. The first processing stream consists only of the transmission of F3X ACH messages between the ODFI and Banxico via the FedACH. Once the ODFI transmits the F3X ACH messages to FedACH, FedACH will edit, process, and send the messages to Banxico. Banxico then will edit and hold the F3X messages pending certain actions taken by the ODFI through an MCFI in the second processing stream of this service. This first phase does not involve any kind of settlement between the ODFI, FedACH and Banxico. The second processing stream involves the ODFI requesting the MCFI to send a payment order to Banxico via the SPEI System that satisfies certain formatting, informational and settlement requirements as set forth in this service manual and the SPEI Rules. Assuming that the payment order from the MCFI satisfies these requirements, Banxico will link this payment order with corresponding F3X ACH messages it receives from FRB and will then send all corresponding items via SPEI to the appropriate receivers’ account at the Mexican RDFIs in accordance with the information contained in the F3X ACH messages. The ODFI is considered the initiator of the payment instruction. The MCFI serves as the ODFI’s settlement correspondent of pesos in Mexico and the SPEI participant that is instructing Banxico as the providing participant to disburse cross-border items according to the SPEI Rules. Payment and Settlement Flows This section describes both processing and delivery schedules for the Mexico Service. ODFIs submit a Nacha formatted file that may contain both domestic and cross-border transactions to FedACH. Cross- border items need to be batched separately within a file. Additionally, ODFIs will need to batch FV items and F3X items separately. FedACH edits the file and validates that receipt is from an eligible participant. 20
You can also read